EU POPs Screening: UV-328, Dechlorane Plus and PBDE Limits

News | 2026-09-09 14:46

EU POPs compliance is no longer a static substance-list exercise. Recent entries and amendments under Regulation (EU) 2019/1021 apply different unintentional trace contaminant (UTC) limits, transition dates and use-specific derogations to UV-328, Dechlorane Plus and five listed PBDEs.

As of 9 September 2026, the first UV-328 limit is already in force, Dechlorane Plus has been added to Annex I, and the recovered-material limit for listed PBDEs has moved to 350 mg/kg. A generic supplier answer stating that a product “complies with POPs” does not show which material, product route, date or derogation was assessed.

Start by separating three regulatory questions

Article 3 of the POPs Regulation generally prohibits the manufacture, placing on the market and use of substances listed in Annex I, whether the substance appears on its own, in a mixture or in an article. The result for a particular material depends on Article 4, the UTC level in the relevant entry and any narrowly defined derogation.

UTC limit: a boundary for an unintentionally present trace contaminant. A result above that level cannot rely on the UTC provision, although a precisely applicable use derogation still needs to be checked.
Use or spare-part derogation: normally conditional on product type, function, original use, repair purpose and an end date. It is not a general approval for a company or an entire finished product.
Waste concentration limit: Annex IV and Article 7 determine when POP content in waste must be destroyed or irreversibly transformed. Those requirements are not interchangeable with the Annex I limits for substances, mixtures and articles.

UV-328: 100 mg/kg is only the first stage

Commission Delegated Regulation (EU) 2025/843 was adopted on 5 May 2025, published on 15 July and entered into force on 4 August 2025. It added UV-328 (CAS 25973-55-1) to Annex I with a staged UTC limit:

100 mg/kg (0.01%) from 4 August 2025;
10 mg/kg (0.001%) from 4 August 2027;
1 mg/kg (0.0001%) from 4 August 2029.

The levels apply where UV-328 is present in a substance, mixture or article. Plastics, rubber, coatings and optical films that use UV stabilisers should therefore be linked to a specific formulation or part number rather than covered only by a finished-product statement.

The entry also contains time-limited derogations. Certain land-based motor vehicles, industrial coatings, mechanical separators in blood collection tubes, triacetyl cellulose film in polarisers, photographic paper, and civilian or military aircraft may qualify until 4 August 2030 under the stated conditions. Several spare-part routes require evidence that UV-328 was initially used in production and apply only until a defined service-life, 2030 or 2043 boundary. Describing a component as an automotive spare part is not enough on its own.

Dechlorane Plus: identify the use before applying the 2028 step-down

Commission Delegated Regulation (EU) 2025/1930 was adopted on 15 May 2025, published on 25 September and entered into force on 15 October 2025. The entry covers the syn- and anti-isomers of Dechlorane Plus and lists CAS numbers 13560-89-9, 135821-03-3 and 135821-74-8.

The UTC limit for Dechlorane Plus in substances, mixtures or articles is 1,000 mg/kg (0.1%) until 15 April 2028. After that date, it becomes 1 mg/kg (0.0001%). A long-life product that will continue to be manufactured or imported after April 2028 needs a material roadmap for the lower stage now; the current number is not a permanent specification.

Specific aerospace, space and defence, medical-imaging, and radiotherapy uses may qualify until 26 February 2030. Repair parts for certain vehicles, stationary industrial machinery, outdoor power equipment, instruments and medical devices may also qualify, but only under the detailed original-use, repair and service-life conditions. Procurement records should identify the component, material function, original design and repair purpose rather than assume that an exemption for the host equipment covers every replacement part.

PBDEs: general material, recovered material and children’s products follow different paths

Commission Delegated Regulation (EU) 2025/1482 reset the combined UTC rules for tetraBDE, pentaBDE, hexaBDE, heptaBDE and decaBDE. It was adopted on 24 July 2025, published on 28 October and entered into force on 17 November 2025.

General mixtures and articles: the sum of the five listed PBDEs is limited to 10 mg/kg.
Mixtures or articles containing, or made from, recovered material containing listed PBDEs: 350 mg/kg from 30 December 2025, falling to 200 mg/kg from 30 December 2027.
Toys and specified childcare products made with that recovered material: 350 mg/kg from 30 December 2025, falling directly to 10 mg/kg from 17 May 2027.

Food-contact materials are excluded from these PBDE UTC provisions; the exclusion does not create permission to use the listed PBDEs at those concentrations. For recycled plastics, the supplier file should identify feedstock origin, sorting controls, batch variability and the final product category. A recycled-content percentage by itself cannot select the applicable route.

Electrical and electronic equipment needs a RoHS routing decision

The Annex I entries for the listed PBDEs retain a specific derogation for electrical and electronic equipment within the scope of Directive 2011/65/EU. Businesses should not apply the 350 mg/kg or 200 mg/kg recovered-consumer-product values as a final EEE limit. They first need to establish whether the product is within RoHS and then assess restricted PBDEs, homogeneous materials and any relevant RoHS derogation.

This routing point is commercially important. The same recycled flame-retardant polymer can lead to different regulatory work when used in a general consumer article, toy, childcare product, food-contact article or EEE. Intended use, material origin and placing-on-the-market timing belong in the evidence file.

Build a material matrix that supports a release decision

Decompose the BOM: map coatings, plastics, rubber, cables, connectors, optical films, flame-retardant parts and recycled feedstock batches.
Resolve substance identity: screen names, synonyms, CAS/EC identifiers and group members so that Dechlorane Plus isomers and the five-PBDE sum are not missed.
Assign the product route: distinguish general articles, mixtures, recovered-material products, toys, childcare products, food-contact materials, EEE and repair parts.
Control dates: create alerts for 17 May 2027, 4 August 2027, 30 December 2027, 15 April 2028 and 4 August 2029.
Test derogation conditions: retain evidence of original use, component function, repair purpose, production and market dates, and the relevant cut-off.
Reopen the review after changes: a new resin, flame-retardant system, recycled source, coating formulation or processor can change the risk profile.

What testing can establish

Targeted chemical testing can provide concentration evidence for UV-328, Dechlorane Plus or PBDEs in a defined material or component. It is particularly useful where supplier data are incomplete, recycled-feedstock batches vary, a high-risk material is being released, or a substitute needs verification.

A laboratory result does not by itself determine whether a substance is unintentionally present, select the legal product category, establish that a use derogation applies, or resolve a waste-management duty. A defensible file connects the report to the BOM, material specification, formulation or supplier declaration, recycled-material source, intended use, market date and derogation matrix. Sampling should also account for different colours, flame-retardant systems, coatings, processors and recycled batches.

How Qianxin can support readiness

Once the product, materials, target market and written scope are defined, Qianxin can support component and material grouping, identification of target-substance testing needs, sample-to-BOM or part-number checks, and a preliminary completeness review of supplier declarations, reports and technical records. Final decisions on legal scope, use derogations, RoHS routing and waste treatment remain with the responsible operator and should be based on the current official text and complete product facts.

This article reflects official information available on 9 September 2026 and provides general compliance guidance. It is not a complete POPs substance list and is not a substitute for product-specific legal advice or a final conformity assessment.

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